Do You Need Country-by-Country Reporting (CbCR) Advisory? A Practical Starting Point
Country-by-Country Reporting is not a form you fill in once a year and forget. It is a live obligation with two separate deadlines — the annual notification and the report itself — administered by the UAE Ministry of Finance under Cabinet Resolution No. 44 of 2020, feeding into an OECD BEPS Action 13 exchange network that reaches over 100 tax administrations worldwide.
What You're Really Buying
Country-by-Country Reporting (CbCR) is the OECD's BEPS Action 13 framework requiring large multinational enterprise (MNE) groups to prepare an annual report that breaks down, on a country-by-country basis, their revenue, profit before tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees, and tangible assets other than cash. In the UAE, CbCR is governed by Cabinet Resolution No. 44 of 2020 (as amended), administered by the Ministry of Finance (MoF), which sits alongside — and now interacts closely with — the UAE Corporate Tax regime administered by the Federal Tax Authority.
For the full scope, current process and what PNPC includes, see the dedicated Country-by-Country Reporting (CbCR) Advisory service page.
When You'd Need This
- 15 billion or more (Cabinet Resolution No.
- The Ultimate Parent Entity of the group is tax resident in the UAE — in which case the UAE entity is the Reporting Entity responsible for filing both the notification and the CbCR itself
- The UAE entity is a Constituent Entity of a foreign-headquartered group above the threshold, and the group has designated the UAE entity as a Surrogate Parent Entity for CbCR purposes, or no exchange agreement exists between the UAE and the UPE's home jurisdiction
- The group is restructuring its holding chain, redomiciling its UPE, or setting up a new UAE holding or regional headquarters entity where CbCR classification needs to be assessed before, not after, the structure is finalised
Before You Assume You Need This
- Standalone UAE companies or small and mid-sized groups whose consolidated group revenue is below the Cabinet Resolution threshold — no CbCR notification or report obligation arises, though general transfer pricing documentation obligations under UAE Corporate Tax may still apply if related-party transactions exceed the relevant materiality thresholds
- UAE free zone or mainland entities that are wholly domestic with no related-party cross-border transactions and no foreign parent or subsidiary — CbCR is inherently a cross-border, group-level obligation and has no application to a purely domestic structure
- A UAE entity that is a Constituent Entity of a large foreign group, where the group's Ultimate Parent Entity in another jurisdiction is already filing centrally and that jurisdiction has an effective exchange agreement with the UAE — in this scenario the UAE entity's obligation is typically limited to the notification, not a full local CbCR filing
Questions We're Actually Asked
What exactly is Country-by-Country Reporting, in plain terms?
It is an annual report that large multinational groups must file, breaking down their revenue, profit, tax paid, employees, and assets by country. Instead of a tax authority seeing only the local UAE entity's numbers, CbCR shows the whole group's global footprint in one document. It exists because, under the OECD's BEPS Action 13 initiative, tax authorities wanted visibility into whether profit is being booked in low-tax jurisdictions that have little real business activity — a pattern known as base erosion and profit shifting.
Which UAE entities actually need to file a CbCR?
15 billion or more (the UAE's expression of the OECD's EUR 750 million threshold, under Cabinet Resolution No. 44 of 2020), and where the Ultimate Parent Entity (or a designated Surrogate Parent Entity) is UAE tax resident. 15 billion and have no CbCR obligation at all.
My UAE entity is a subsidiary of a foreign parent that already files CbCR in its home country. Do we still have an obligation here?
Usually yes, but a lighter one — the CbCR Notification. Even where the full report is filed centrally by the foreign Ultimate Parent Entity and reaches the UAE through automatic exchange, the UAE Constituent Entity typically still has to file an annual notification confirming which entity is filing the group's CbCR and in which jurisdiction. Only in specific circumstances — such as the absence of an effective exchange agreement between the UAE and the UPE's jurisdiction, or a systemic failure to exchange — would the UAE entity itself be required to file a full local CbCR as a Surrogate Parent Entity.
Working With PNPC Global
CbCR is a group-level obligation with jurisdiction-specific deadlines and real cross-border audit consequences — talk to PNPC's Dubai international taxation desk before your next filing window, not after a foreign tax authority's query arrives.
PNPC Global has advised Dubai businesses since 1986. Explore the full NRI & Cross-Border Compliance practice for related services, or go straight to the Country-by-Country Reporting (CbCR) Advisory page for specifics.
This is a general explainer, not a substitute for checking today's rules with PNPC or the relevant authority — figures and deadlines move, so none are quoted here as fixed.